Not legal advice. We checked this guide against official sources on 28 August 2026. Before you spend money or stop shipping somewhere, check with that country's packaging authority or an approved recycling scheme. The representative rule may change, but the current rule still applies.
Why you're hearing about this now
The EU Packaging and Packaging Waste Regulation (PPWR), formally Regulation (EU) 2025/40, started applying on 12 August 2026.
For a small fingerboard brand, the main question is how you sell. If you're based in the EU and ship directly to a customer in another EU country, you become the packaging producer in that country. You must register there, follow its EPR rules and appoint a local representative.
If you only sell at home, you do not need a representative abroad. Your national packaging rules still apply. You may also need to keep paperwork for packaging you make or sell under your brand. If a shop abroad buys your decks and resells them, the shop is normally the producer there. Most of the new design and sorting-label rules come later.
The 30-second version
- You only sell inside your own country: no foreign representative is needed. Check your national packaging rules and keep the documents supplied with your packaging.
- You ship directly to customers in other EU countries: register and follow the EPR rules in each country you ship to. You also need a representative there. Small sellers are not generally exempt.
- You sell wholesale to a shop abroad: the shop that imports and resells your products is normally the producer there.
- You ship outside the EU: these EU destination-country EPR duties do not apply. The destination may have its own packaging rules.
- You use less than ten tonnes of packaging: you get simpler reporting, not an exemption.
How packaging EPR works
EPR stands for extended producer responsibility. It means that the business putting packaging into a country helps pay for the waste it creates. You register, report how much packaging you send and pay the relevant fees. Each country runs its own system.
The important bit: the "producer" is not necessarily the company that made your mailer. If you put a deck in it and ship the filled parcel directly to a customer in another country, packaging law may treat you as the producer there.
Buying your boxes locally does not change this. When you fill one and send it directly to a customer abroad, you are the producer in the destination country. The company that made the empty box may still be its manufacturer. The Commission's official guidance explains the difference.
What changed (and what didn't)
Country-by-country packaging EPR is not new. Germany's Packaging Act and LUCID registration took effect in 2019, then registration and marketplace checks expanded in July 2022. France has required producers subject to EPR to hold a unique identifier (IDU) since 2022. Other member states run their own systems.
What the PPWR changed on 12 August 2026:
- Direct sales now follow one EU-wide definition. If you sell through your shop, Instagram or Etsy directly to someone in another EU country, you're the producer there. This also covers a business buying a deck for its own use.
- You need a representative in each destination country. This is a person or company based there that handles the EPR work on your behalf. It can be the main new cost for small EU makers selling directly across borders (Article 45(3) of the regulation).
- Marketplaces must check sellers. They ask for your registration number and a statement that you comply. Etsy already asks for LUCID details for Germany.
- Registration is still country by country. There is no single EU register. Less than ten tonnes gives you simpler reporting, not an exemption. The Commission's FAQ confirms this.
- Packaging paperwork also matters now. If the PPWR treats you as the manufacturer, you must be able to show that your packaging meets the rules already in force.
Producer and manufacturer are different jobs
The two words sound similar, but they describe different jobs.
The producer registers and pays EPR fees in the country where the packaging becomes waste. The manufacturer proves that the packaging itself follows the PPWR.
If you buy a standard, unbranded mailer, the company that made it is normally the manufacturer. Adding a shipping label or sticker does not change that. If you order packaging with your brand or your own design, you may become the manufacturer. If your business is very small and the supplier is in the same country, the supplier may keep that role. Ask them to confirm it.
If you are the manufacturer, you need a technical file and an EU declaration of conformity. The packaging also needs an identifier, such as a type or batch number, plus the manufacturer's contact details. If the packaging is too small, this information can go in a document sent with the product.
For most small makers, the practical rule is simple: keep the documents supplied with standard packaging. Before ordering branded or custom packaging, ask the supplier in writing who will be the manufacturer. If it is you, ask for the information you need to prepare the technical file and declaration.
Does this apply to you?
Say you press decks in France and sell through your own shop and Instagram.
You sell a deck to a customer in France
No foreign representative is needed. French packaging rules still apply, and you should keep the documents supplied with your packaging.
You ship a deck directly to a customer in Germany
You're the producer in Germany. You need to register with LUCID, join a German recycling system and appoint a German representative. Check every other EU country you ship to in the same way.
You sell ten decks wholesale to a fingerboard shop in Berlin, which resells them
The German shop is normally the producer because it imports and resells the decks. Make sure the shop understands that it will handle the German packaging duties.
You sell to a German customer through Etsy
This is still a direct sale. Etsy does not take over your obligations and may ask for the relevant registration details.
You ship to a customer in the UK, US or Japan
The EU packaging EPR rules covered by this guide do not apply to that parcel.
A German company buys a deck for its office
The company is still an end user, so the direct-sale requirements apply.
The numbers, using a deck shipment
Take a deck shipment with a 60 g cardboard mailer and 10 g of plastic packaging. After 100 parcels, you have sent 6 kg of paper and 1 kg of plastic. Packaging systems may ask for figures like these.
At 70 g of packaging per parcel, you would need to send roughly 143,000 parcels to one member state in a calendar year to reach ten tonnes there. The threshold changes how you report in that country, not whether EPR applies.
At low volume, the fixed costs matter more than the weight of the packaging. You may need to pay a minimum scheme charge, registration costs and a local representative. A Commission staff working document found representative services advertised from several hundred euros. Prices vary, so get a current quote for each country.
If the total cost for one country is €300 a year, that is €100 per order when you send three orders, or €7.50 per order when you send 40. This is why occasional direct sales can be difficult to justify.
Your options, country by country
For each EU country you ship to, you have three main options:
1. Register where the sales justify it. Start with the countries where you send the most orders. Ask for one quote covering registration, EPR fees, reporting and the local representative.
2. Sell through a shop or distributor. A shop that imports and resells your decks will normally be the producer in its country. Make sure it knows that before you agree to wholesale.
3. Turn off direct shipping to some countries. You can remove a country from checkout until you have enough orders to cover the cost or find a local shop.
If you're a rider, you can browse brands by country to find makers closer to home.
If you keep selling cross-border: the checklist
- 1 List your orders by country. Separate direct customer orders from wholesale orders sent to shops.
- 2 Check your home-country rules. Make sure your current registration is in order and keep your packaging supplier's documents.
- 3 Record your packaging. Note the weight of paper, plastic and other materials in each parcel type.
- 4 Check your main EU destinations. Ask what registration, fees, reports and local representative you need.
- 5 Choose where to sell directly. Register, sell through a local shop or turn off direct shipping.
- 6 Update your shop and marketplace accounts. Add registration numbers and remove countries you are not ready to serve.
- 7 Keep simple records. A spreadsheet with the date, country, parcel type and material weights is a good start.
What applies now, and what comes later
Some of the PPWR changes being discussed do not apply until 2028 or 2030. The timings below come from the Commission's FAQ.
2026
You are here
- Direct sellers to end users are producers in each EU country they ship to
- A local representative is required for those sales
- Marketplaces and fulfilment providers check registration
- Packaging manufacturers need documents and traceability details
2028
Earliest date
- Harmonised material and sorting labels from 12 August 2028 at the earliest
2030
Or later
- Packaging minimisation from 1 January 2030
- 50% empty-space limit from 1 January 2030 at the earliest
- Recyclability grades and recycled-plastic targets, with some exemptions
- First harmonised EPR reports due to national registers by 1 June 2030
You do not need the future sorting label or the 2030 packaging changes yet. There is also no single EU reporting portal. For now, focus on EPR registration, the local representative and keeping your packaging documents.
A few common myths
Buying packaging locally does not remove your EPR duties when you send it directly to a customer in another EU country. It may change who is the packaging manufacturer, but not who handles EPR for the cross-border sale.
Marketplaces check compliance, but they do not automatically handle it for you. A platform can pay EPR fees if you give it written permission. It can only register and report for you if you formally appoint it as your representative.
Marketplaces must collect and check registration details. Fulfilment providers must ask you to correct missing or inaccurate information, then suspend their service if you do not fix it. Authorities should warn you and allow you to correct a problem before taking further action.
What might change soon
The Commission proposed pausing the representative rule until 2035. The Council stopped working on the proposal in April 2026 after opposition from member states (Council progress report). Parliament is still considering it and is expected to vote on 5 October 2026 (procedure file 2025/0395(COD)). Parliament's rapporteur wants the pause to apply only to micro and small businesses.
Nothing has changed yet. A Parliament vote is not enough on its own: the Council must also agree. The proposal only concerns the representative rule. It does not remove registration, reporting or EPR fees.
We'll update this guide when the procedure moves forward.
Corrections welcome. If something here doesn't match what you're seeing in the real world, get in touch on Instagram or Discord and we'll fix it.